Tax Breakfast | Local File Exemptions: Questions and Answers

Date: 20 June

Time: 10:00 am-11:30 am

Place: Onsite event


The 2019 legislation introducing an exemption from the obligation to prepare a local file for domestic transactions has significantly simplified the transfer pricing reporting process.

The correct identification of controlled transactions subject to the exemption eliminates the obligation for them to have associated local file and benchmarking analyses. This also enables the correct completion of TPR forms, protecting taxpayers from severe sanctions.

However, practice shows that the regulations on the exemption from the obligation to prepare the local file still raises questions and doubts as to interpretation.

This is why we would like to invite you to the first in a series of tax breakfasts devoted to transfer pricing, during which we’ll answer your questions and hopefully dispel the most common doubts.



  • Identification of transactions subject to exemption from the obligation to prepare a local file
  • No tax loss as a condition for enjoying the exemption from the documentation obligation:
    • No tax loss, i.e. no loss from the source of income to which the controlled transaction is related
    • The concept of tax loss in the case of partnerships and Estonian companies
    • Does a tax loss incurred only by some of the entities involved in the transaction prevent the exemption?
    • Retained loss and the exemption from documentation obligation
  • Local File exemption for state-owned companies: theory vs. practice



Andrzej Malec, PhD – the Partner supervising the K&P Transfer Pricing team. For several decades he has been supporting key domestic and foreign companies in complying with transfer pricing obligations.

Katarzyna Pustułka – lawyer and economist, PhD student at the Warsaw School of Economics (SGH), bar trainee, with many years’ experience of working within transfer pricing projects.


Who should attend?

The event is addressed to CFOs and chief accountants of entities carrying out domestic transactions with related parties.

You can read more about transfer pricing in our Tax Focus.



Participation in the event is free of charge, following registration and acceptance of applications. The organizer reserves the right to cancel the event.

This is an onsite event. Places are limited and priority will be given to CFOs and chief accountants.

Venue: Offices of Kochański & Partners, pl. Piłsudskiego 1, Warszawa.

Tax Breakfast | Local File Exemptions: Questions and Answers

20 June

10:00 am-11:30 am

Onsite event

The controller of your personal data is Kochański & Partners sp.k. with its registered office at Plac Piłsudskiego 1, Warsaw (00-078), registered in the Register of Business Entities kept by the District Court for the capital city of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000625481. For more information on the processing of your personal data, please visit: